STF 279 Changes to be introduced to ETSI

STF 279 Changes to be introduced to ETSI Guide ETSI EG 201 399 v 1. 3. 1 & Pro-forma ETSI SR 001 470 v 1. 1. 6 Document STF 279 020 STF 279

Introduction q. Substance of Guide and Pro-forma remains sound q. EG & SR could have been applied more rigorously q. Tone & context no longer appropriate q. Different emphasis would be appropriate 1/8/2022 STF 279 2

Proposed Changes q EG & SR should be combined q Editorial Elements of the SR Pro-forma should be incorporated in the materials supported by Edit. Help q Background information in section 4 of EG to be removed q Any information in section 4 should be retained in an annex q Standard introduction in pro-forma should incorporated into EG as an annex q “Scope” of HS to be unambiguous q Use of expressions such as “test suite”, “ERTS” & “other test suites to be reviewed 1/8/2022 STF 279 3

Proposed Changes q EN-RT should be mandatory and restructured to remove ambiguity q Where HS covers apperatus intended to be available separately, then separate EN-RT should be generated for each part q EG should clarify that generally Rx parameters (other than Spurious emissions) are not to be specified in HS unless Rx directly affects Tx parameters, or a 3. 3 requirement has to be fulfilled q Normative References must be uniquely identified unless reference to a HS is made (at the discretion of the TB) 1/8/2022 STF 279 4

Proposed Changes q Informative text etc may be included in HS (but clearly identified as such) q Where relationship between requirement/test and corresponding essential requirement is not evident “rationale” for inclusion should be provided (a separate informative annex is preferred) q Section 6 of EG to be decoupled from annex A integrating relevant concepts from A. 2 into section 6 with a checklist for confirming relevance to essential requirements q The justification of all requirements against the decision tree should be removed. (However the principles indicated in the decision tree should be retained in the EG. ) q Where TB deviates from the guidance, OCG R&TTE SC should be informed 1/8/2022 STF 279 5

Proposed Changes q Where equipment “Scoped” in HS is the object of other legislation the HS must not include normative info with regard to that other legislation unless there is an explicit cross reference in the legislation itself. Where there is no such cross reference, informative references to such legislation can be made without giving the impression that complience with HS gives presumption of conformity with anything other than R&TTE. q HS should address complete application of one essential requirement under R&TTE. If not this must be made clear q Informative references to specific requirements/tests relevant to essential requirements outside the scope of the HS should not be made q Guidance concerning Antennas in EG should reflect the further deliberations in TCAM 1/8/2022 STF 279 6

Because of the regulatory status of a HS, statements of the following types should be avoided: q Statements referring to the role of national authorities in general, for example indicating that national authorities may relax the standards requirements, ignore them or make them more severe. q Statements concerning the legal responsibilities or legal roles of parties involved (manufacturers, operators, authorities etc. ). q Statements referring to sales restrictions, legal sanctions, obligations for entering the market, ban of sales, contractual arrangements/ relations between parties. q Statements imposing obligations outside the scope of the standards, for example an obligation to perform tests in locations defined by non-technical parameters, such as manufacturers’ premises or third party laboratories. Note: Only technical requirements may be imposed to test locations. 1/8/2022 STF 279 7

Statements to be avoided: q Statements related to cases of dispute, such as "In case of dispute, the method used by the manufacturer shall be used". Note: Where alternative test methods are provided, the principle should be that compliance with the requirements may be demonstrated by either or any of the methods described in the standard. q Statements including dates of regulatory application Note: If ETSI Technical Bodies find it useful to give advice in such matters, it should be done in separate documents and not included in the text of standards. This does not apply to information about national transposition of standards. q Statements introducing provisional limits or requirements. 1/8/2022 STF 279 8

Other Proposed Changes q The ETSI Technical Officer concerned should be proactive in his/her role of advising Technical Bodies about the drafting guidance. q When considering revision of HS, TB must take due account of implementation costs for industry. q HS titles should be translated into all the EU languages. 1/8/2022 STF 279 9

Essential Radio Test Suite (ERTS) Apperatus meets relevant HS (complying with all essential requirements/tests) = Member States presume compliance with essential requirements covered by the standard Unless HS allows essential tests to be applied on a selective basis dependent apperatus features Relevant parts of HS applied in full to achieve compliance [but note that some tests are non-essential contrary to STF view] 1/8/2022 STF 279 10

ERTS q Not permitted for manufacturer, at his own discretion to “mix and match” normative requirements/tests q STF 279 believes these requirements prevail, when seeking to establish the presumption of compliance q This principle must be clear in all HS q If a particular test may be omitted or alternative used then the test cannot have essential status (although underlying requirement is normative) q The understanding of “EN-RT”, “ERTS” and “Other Test Suites” must respect this principle 1/8/2022 STF 279 11

ERTS Proposal q IN R&TTE “ERTS” Applies only to Tx q STF 279 considers Rx parameters may be pertinent to “R&TTE essential requirements” q STF 279 proposes the concept of “ERTS” can be applied to the above cases (for Rx) q ERTS becomes the totality of essential tests specified in a HS. {Note: you can have a test which is not essential } 1/8/2022 STF 279 12

Conclusion q Current EG states test methods should be specified only where “…the value obtained may vary according to the method of measurement employed…” q Accordingly all tests specified become part of the ERTS or Other tests at the descretion of the TB concerned. 1/8/2022 STF 279 13